- 21 - return (Schedule E), petitioners reported, inter alia, “Rents received” of $23,013 with respect to the Loomis residence. The $23,013 that petitioners reported in Schedule E as rent with respect to the Loomis residence included the $5,100 of Loomis residence monthly payments that Olin Ordnance reported in Form 1099 as part of the $52,894.31 of nonemployee compensation that it paid to Mr. Palmer during 1995 pursuant to paragraph 5 and Exhibit D of the Marion plant/Palmer consulting agreement. In Schedule C, Profit or Loss From Business, of the joint return (Schedule C), petitioners reported in Part I, Income, gross receipts of $47,794, which was the amount ($52,894.31) of nonemployee compensation that Olin Ordnance paid to Mr. Palmer during 1995 and reported in Form 1099 reduced by the amount ($5,100) of Loomis residence monthly payments that petitioners claimed in Schedule E as rent with respect to the Loomis resi- dence. In the notice of deficiency (notice) issued to petitioners for the year at issue, respondent, inter alia, increased petition- ers’ Schedule C reported gross receipts by $95,935 because respon- dent determined that during 1995 Mr. Palmer had constructively received that amount of nonemployee compensation from Olin Ord- nance.11 Respondent also determined that the $5,100 of Loomis 11The $95,935 by which respondent increased petitioners’ Schedule C gross receipts for the year at issue because respon- (continued...)Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011